The Bruce Trail Conservancy …

The Bruce Trail Conservancy (BTC) is one of Ontario’s largest land trusts and the steward of Canada’s longest marked footpath. Our mission is to preserve a ribbon of wilderness, for everyone, forever. To accomplish this, we conserve, restore and manage land along the Niagara Escarpment UNESCO World Biosphere to protect its ecosystems for the benefit of all. We make it available to explore by foot along the Bruce Trail and within our protected natural areas.

The BTC has reviewed the proposed legislative amendments associated with this ERO proposal posting, along with the various other postings associated with Ontario’s Housing Supply Action Plan 2022-23. We have also met with government officials and staff to gain clarification regarding what is being proposed and the potential impacts on our mission.

The BTC agrees that there is a housing supply and accessibility issue in Ontario that needs to be addressed. The Bruce Trail Conservancy supports the government’s commitment to reducing barriers to housing for all, and we are optimistic there can be a balance between the growing needs of communities and positive conservation outcomes.

However, the BTC has some concerns about the proposed amendments to the Conservation Authorities Act and the impacts these amendments may have on the safety of trail users and the ecological health of the Niagara Escarpment conservation corridor that we work hard to protect. In particular, we are concerned that conservation authorities will no longer be able to consider the ‘conservation of land’ and pollution when reviewing development applications, and that certain types of development could be exempted from requiring a conservation authority permit.

We ask that the government continue to allow Conservation Authorities to consider conservation of land and pollution when reviewing applications. The conservation of land is important for ensuring the land’s ecological health which, in turn, ensures that we benefit from the ecosystem services provided by the land. These nature-based services include flood and natural hazard mitigation, which is increasingly crucial for adapting to the effects of climate change. We recognize that the conservation of land is both directly important for maintaining the Escarpment conservation corridor, and also indirectly helps protect the trail and trail users from flooding and other hazards. Thus, we believe the consideration of conservation of land supports conservation authorities’ work in addressing natural hazards. We also believe the consideration of pollution is important for ensuring water quality in surrounding areas. As the BTC protects many wetlands and water features within our conservation corridor, we want to ensure that nearby development does not negatively impact these wetlands and the species they support.

Furthermore, we are concerned with the proposal that certain types of development could be exempted from requiring a Conservation Authority permit. As municipalities have limited resources to consider the potential impacts of development on natural hazards, the permitting process used by conservation authorities is crucial for weighing all potential impacts and ensuring they are mitigated. Furthermore, conservation authorities have the means to enforce the conditions of the permits that they provide, and if they do not play a role in providing permits for certain developments, municipalities may not be able to fill in the enforcement gap. Ultimately, we are concerned that exempting certain activities from Conservation Authority oversight may lead to increased hazards and damage to the natural environment, including the Niagara Escarpment corridor.

We urge the government to reconsider these proposed changes and further consult with Conservation Authorities on these matters.